Plaintiffs' Motion to Clarify District Boundary Lines for Lawrence County; Order Clarifying Election Districts for Lawrence County

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BLACKSHER, MENEFEE & STEIN, P.A. | 

ATTORNEYS AT LAW 

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JAMES U. BLACKSHER 

GREGORY B. STEIN LARRY T. MENEFEE 

405 VAN ANTWERP BUILDING November 4, 1986 FIFTH FLOOR TITLE BUILDING 
P.O. Bax 1051 300 2187 STREET, NORTH 

MOBILE, AL 36633-1051 BIRMINGHAM, AL 35203 

(205) 433-2000 : (205) 322-7300 0R 322-7313 

The Honorable Myron H. Thompson 
United States District Judge 
Middle District of Alabama 
United States Courthouse 
15 Lee Street 
Montgomery, Alabama 36104 

Re: Dillard v. Crenshaw County, 
Civil Action No. CV 85-T-1332-N 
    Dear Judge Thompson: 

Enclosed is a motion to clarify the boundary lines between | 
districts one and two for the Lawrence County Commission. I | 
believe the motion is self-explanatory. No verbal descriptions 
were prepared. The parties intended.that the residents affected 
by this clarification should in fact.be in district two. 
Specifically, one of the incumbent commissioners lives on the 
west side of the road when we (both plaintiff and defendant 
counsel) understood he lived on the east side of the road. 

This confusion arose because of inaccurate information 
supplied to the demographers when they were drawing the lines. 
The requested clarification will in fact implement the intent of 
the parties. 

  
Either myself, Mr. Blacksher or Mr. Still will be available 

for a conference if necessary. I have discussed this with Mr. 
Boyd. While he is not willing to be a movant for this 
clarification, he will confirm the correctness of the facts 
alleged in our motion and does not oppose this motion. 

Sincerely, | 

BLACKSHER, MENEFEE & STEIN 

BY: 
  

ARRY/T. MUNEFEE 

 



  

LTM:bj] 

Enclosure 

cc: David R. Boyd, Esq. 
James U. Blacksher, Esq. 
Edward Still, Esq. 

 



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 
  

JOHN DILLARD, ET AL., 

Plaintiffs, 

Vv. CIVIL ACTION NO. CV 85-T-1332-N 

CRENSHAY COUNTY, ALABAMA 
ET AL., 

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Defendants. 

PLAINTIFFS' MOTION TO CLARIFY DISTRICT 
BOUNDARY LINES FOR LAWRENCE COUNTY 
  

Plaintiffs move the court to enter an order clarifying 

that the boundary line between districts one and two of the 

court-approved plan for Lawrence County Commission elections be 

defined in part as follows: 

That portion of the court-approved boundary 
separating commission districts one and two for 
Lawrence County on the eastern boundary of the City of 
Town Creek north of Highway 20 to the Southern Railroad 
track shall include residents of both sides of said 
road. 

1. The parties had agreed to this line and the above 

description correctly reflects the intent of the party to include 

these residents in commission district two. 

2. It would normally be assumed from reading a map that 

the district line ran down the middle of said street or road, 

however, no verbal description has been prepared of these 

districts and this clarifying amendment would properly reflect 

the intent of the parties. 

WHEREFORE, parties request that the court approve this 

 



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clarification of the district boundary lines and allow any 

candidates who incorrectly qualified to run for office because of 

this confusion to change their qualification to the correct 

district. 

BLACKSHER, MENEFEE & STEIN 
Fifth Floor Title Building 
300 Twenty-First Street North 
Birmingham, Alabama 35203 
(205) 322-7300 

  

. BLACKSHER 
WANDA J. COCHRAN 

JERRY 6. DAVIS 
SEAY & DAVIS 
732 Carter Hill Road 
P.O. Box 6125 
Montgomery, Alabama 36106 
(205) 834-2000 

DEBORAH FINS 
JULIUS L. CHAMBERS 
NAACP LEGAL DEFENSE FUND 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

EDWARD STILL 
REEVES & STILL 
714 South 29th Street 
Birmingham, Alabama 35233-2810 
(205) 322-6631 

REO KIRKLAND, JR. 
307 Evergreen Avenue 
P.O. Box 646 
Brewton, Alabama 36427 
(205) 867-5711 

Attorneys for Plaintiffs 

 



  

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CERTIFICATE OF SERVICE 
  

This is to certify that a copy of the foregoing has 

been served upon the following by depositing same in the United 

States Mail, postage prepaid or by Federal Express, on this the 

¢* say of 2/8 SA 1986:   

D. L. Martin, Esq. 
215 South Main Street 
Moulton, Alabama 35650 
(LAWRENCE COUNTY, SMITH & LIGON) 

David R. Boyd, Esq. 
BALCH & BINGHAM 
P.0. Box 78 
Montgomery, Alabama 36101 
(LAWRENCE COUNTY, SMITH & LIGON) 

BLACKSHER, MENEFEE & STEIN 

   



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 
  

JOHN DILLARD, ET AL., 

Plaintiffs, 

Vv. CIVIL ACTION NO. CV 85-T-1332-N 

CRENSHAY COUNTY, ALABAMA 
ET AL., 

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Defendants. 

ORDER CLARIFYING ELECTION DISTRICTS 
FOR LAWRENCE COUNTY 
  

On plaintiffs' motion the court hereby clarifies the 

boundary lines between commission disticts one and two in 

Lawrence County as originally understood by the parties to 

include residents on both sides of the road defining the eastern 

boundary of the City of Town Creek north of Highway 20 and south 

of the Southern Railway. 

Qualifying is reopened to the extent that any candidate 

who qualified for county commission election and is affected by 

this clarification will be allowed to change their qualifying 

papers to the correct district. 

DONE this day of ,. 1986, 
  

  

UNITED STATES DISTRICT JUDGE